Bulgaria’s final document does not include policies on climate change as criteria for using European funds

On the other hand, having an “adaptation strategy” is an excuse for the appropriation of EU funds. In June 2015 MOSV initiated a process for developing a national strategy for adaptation to climate change, which is expected to be completed by the end of 2017 – the middle of the programme period, and until then, the EU funds will be appropriated without planning of adaptation measures. The Ministry of Environment and Water does not consider the lack of such a strategy as a shortcoming.

Another problem is the possibility that very soon – indirectly and after the fact – we will find out that the EU Commission may induce sanctions on OP funding due to failure to implement decisions taken by various councils and/or failure to comply with requirements arising from such decisions. And since it is common practice to lack publicly available information both regarding the positions which Bulgaria holds at EU and international forums and regarding the reports from such events (the transcripts from ministry meetings only note “Accepted” for the document/report), we cannot know whether and how the decisions from different forums and council meetings are taken into account and implemented here, and whether we should expect international sanctions.